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Safeguarding Policy

Last updated: September 2022

Welcome to Clu, and thank you for taking the time to read our Safeguarding Policy ("Policy"). Clu is an inclusive recruitment platform purposefully designed to create equity of opportunity in the job market. We are passionate about social inclusion and are committed to providing Job Seekers and Employers the opportunity to connect via our platform.



Included.AI Ltd (collectively, "Clu", "we", and "us") is committed to ensuring any person, company, and unincorporated body (whether having a separate legal personality or not) that is interested in hiring Job Seekers (“Employers”, “you”, “yours”) promotes the welfare and safeguarding of the vulnerable adult communities (“VACs”) they can engage through Clu.

The Safeguarding Vulnerable Groups Act (SVGA) 2006 and The Safeguarding Vulnerable Groups (Northern Ireland) Order 2007 legislations underpin safeguarding law in the UK.


This Policy outlines the expectations of engagement with Clu Job Seekers from VACs. 

We strive to ensure the inclusive and equitable experience of all Job Seekers who use Clu and are committed to safeguarding and promoting the welfare of all users.

VACs currently using Clu include but are not limited to disabled and neurodiverse people, refugees and displaced people, former offenders with unspent convictions, older people over the age of 50, younger people between the ages of 17-21 and the long-term out of work.

Employers using Clu must ensure their HR processes, notably their attraction, recruitment, and onboarding processes, meet the reasonable standards of safeguarding outlined in this Policy.

Employers must be able to demonstrate support and measures that afford greater protection to Job Seekers from VACs.

Employers can receive applications from vulnerable Job Seekers through Clu, so these provisions should be in place prior to requesting access to Clu.

Clu accepts no responsibility for breaches in Safeguarding by Employers and cannot be held accountable for any such breaches.

Engaging VACs through Clu

To access Clu, you will be asked to confirm measures currently in place to support vulnerable Job Seekers. This declaration will establish which VACs you can engage through Clu once access is granted. More information on this is available below under “Verification”.

At any time, you can utilise our declaration feature on the Clu website, where you can submit information about any new or updated HR processes you have in place to support additional VACs.

Clu will independently analyse and evaluate this information without bias and if it is deemed sufficient, will grant permission to engage the specific VACs the submission/s pertains to only.

Clu reserves the right to cease access to VACs if there is reasonable evidence to suggest a safeguarding breach or any misuse of the Clu website.



Clu Verification ensures equitable service provision to those from VACs and other underutilised communities.

Verification covers the inclusivity of your hiring processes and is broken down into ten sections that you are scored against to gain Verification.

Passing Verification enables you to directly engage with more talent in the Clu platform, including relevant VACs, subject to the information provided and your score.

​Verification takes approximately two weeks and lasts for twelve months.

Verification must be renewed annually and does not carry over beyond twelve months unless expressly agreed by Clu.

Any assets or materials given to you upon passing Verification can only be used during the period of Verification. If you do not pass Verification or if your Verification expires, you must cease using assets or materials associated with Verification immediately.

If you do not pass Verification, you may still use Clu, but you will not be able to proactively engage Job Seekers from VACs until the submission of support measures has been verified.

Recruitment process

You will actively promote equity of opportunity for all Job Seekers you engage through Clu.

You will open all relevant job opportunities to Job Seekers from VACs and be unbiased in the types of roles you promote to them and consider them for.

You will welcome applications from vulnerable Job Seekers, so long as their skills align with those you advertise in the jobs your post to Clu.

You will make all reasonable adjustments as required by vulnerable Job Seekers.

You will assess vulnerable Job Seekers consistently with other Job Seekers.

You will use the Clu skills-first selection process to assess any vulnerable Job Seeker in a hiring process they’re engaged in.

You will pay vulnerable Job Seekers equitably with other Job Seekers.

If a vulnerable Job Seeker is hired, you accept responsibility for ensuring staff who will be engaging with that individual will be DBS checked and trained accordingly.


Organisational training

You agree to ensure that all line and hiring managers are trained to support vulnerable people at work.

You must ensure that all employees and colleagues undertake training to spot and deal with safeguarding issues appropriately and efficiently confidently.

It is your responsibility to ensure that staff have the correct knowledge and that suitable processes are in place.


Raising Safeguarding concerns

If you believe a vulnerable Job Seeker is being abused or neglected, you must raise a safeguarding report.  

If you are aware of a safeguarding concern, you should take it seriously and act accordingly. You should not be constrained in your view of what constitutes abuse or neglect and should always consider the circumstances of the individual case. 

If there is reason to believe an interviewer, hiring manager or third party engaged in the recruitment process has abused or neglected a vulnerable Job Seeker, you agree to report it to authorities or an adult safeguarding lead in your organisation as soon as possible. 

It is your duty to flag cases where there may be physical evidence of abuse or neglect to the Police immediately. 

As soon as a safeguarding flag has been received, you must make a written record of what you’ve seen, what you’ve been told, or what you have concerns about.

If there are multiple witnesses to a safeguarding breach, you must ensure each witness makes a written report. 

The written report will need to include the date and time when the disclosure was made, who was involved and exactly what happened.  

It is best practice to remember to include as much detail as possible, keep the report factual as far as possible and keep the report confidential, storing it in a safe & secure place until needed. 

Disclosure and Barring Service (DBS)

Some jobs require a DBS check as part of the hiring process, and different levels of checks can be required for different reasons.

You may decide that a basic DBS check is required for a job as many jobs require a basic DBS check. These include but are not limited to teachers, social workers, childminders, foster carers, medical professionals, solicitors, accountants, and others working in regulated industries.

If a DBS check is required to qualify for a job offer, you must clarify this information in the job advert posted on the Clu Website. 

The level of DBS check needed must be based on the nature and responsibilities of each role and should not be defaulted because a Job Seeker is introduced through Clu.

The level of the checking procedure should depend on the level of responsibility associated with caring for, training, supervising or being in sole charge of persons under 18 and/or other adults at risk.

Clu does not complete DBS checks on any registered Job Seeker and is not responsible for completing or carrying out DBS checks on any Job Seeker engaged by you through the Website.

Clu is not responsible for any information not included in DBS checks where an applicant has previously lived overseas.

You should ensure that you have access to all the information available to make safer recruitment decisions. If you are unsure whether a DBS check will be needed for a particular job, you should contact the Disclosure and Barring Service or use their online eligibility checking tool. More information about how to get a criminal record check for overseas applicants, or those that have previously lived outside of the UK is available on the Home Office website.

Completing DBS checks for Transgender Job Seekers

If an applicant is Transgender, a confidential DBS checking process must be adhered to.

This process is for transgender applicants who do not wish to reveal details of their previous identity to the person who asked them to complete an application form for a DBS check.

For more information about the transgender process, email or see the DBS Transgender Applications guidance.

Applicant Rights and DBS

Usually, a Job Seeker has no legal obligation to reveal spent convictions. If a Job Seeker has a conviction that has become spent, you must treat the applicant as if the conviction has not happened.

Refusal to employ a rehabilitated person on the grounds of a spent conviction is unlawful under the Rehabilitation of Offenders Act (ROA) 1974.

Certain areas of employment are exempt under the ROA 1974 (Exceptions) Order 1975, and employers may ask about spent convictions. In these circumstances, the Job Seeker is legally obligated to reveal spent convictions.

Information on a DBS certificate should only be used in the context of a policy on recruiting former offenders.

When an applicant with an unspent conviction applies for a job with an Employer that has passed Verification and can demonstrate a Recruiting Ex-Offenders Policy, Clu can, at its discretion, act as an intermediary between the Employer and Job Seeker to discuss the nature of the conviction and if it is one the Employer can accept.

Withdrawing an applicant's job offer due to the results of their DBS check can be challenged on the grounds of discrimination, so you are encouraged to act fairly and correctly regarding DBS checks. 

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